Sorry it has taken so long to get a response back to the discussion group
about allotments, arsenic and soil management strategies.
Thank you to those who responded to my enquiry. The gist of the responses
was that soil management in this context is not practicable. Practicability
being an issue with regard to Part IIA (section C.19 of the Statutory
Guidance).
Other issues raised were:-
1. Was uptake by crops considered? - This was included to some extent in
the quantitative risk assessment used. Recently grown crops were not
available for bioaccessibility testing.
2. Was a risk assessment carried out? - The consultants had presented a
quantitative risk assessment using an adult as the critical receptor. The
issue raised by our legal people was whether this was appropriate in this
context where children may accompany adults to the allotments. Including a
child as the critical receptor in this context may be conservative but it is
therefore very protective of public health and also helps to deal with the
liabilities issues as raised by the lawyers. Now that CLEA is available it
has been interesting to run the model with real data and compare the results
to those from other risk assessment packages.
Thanks again for the responses, they helped me justify the stance I was
taking in relation to the practical issues.
Cheers
Ann
---------------------------------------------
Ann Barker
Pollution Control Officer
Lead Officer (Contaminated Land)
Specialist Pollution Team
Environmental Protection Division
City of Bradford Metropolitan District Council
Town Hall
Kirkgate, Shipley
West Yorkshire BD18 3EJ
Tel. 01274 757003
Fax. 01274 532767
email: [log in to unmask]
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